PRIVACY POLICY

Last Updated: July, 22, 2026

1. DATA CONTROLLER

In compliance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD), the Data Controller responsible for the processing of your personal data gathered through this website is:

• Legal Entity/Name: Dominik Sebastian Hoffmann / Modulate Studio
• Tax Identification Number (NIF/CIF): Z3731987-N
• Registered Address: C/ Valencia 13, Piso 3, Puerta 6, 46120 València
• Contact Email: info@modulate.am

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2. DATA COLLECTED, PURPOSES, AND LAWFUL BASIS

We only collect personal data that you voluntarily provide to us through our Webflow forms. Depending on how you interact with us, your data is processed as follows:

A. Contact and Inquiry Forms

• Data Collected: Name, email address, and any personal data you voluntarily include in your message through our message fields.
• Purpose: To manage, process, and respond to your inquiries, requests, or questions submitted through our website.
• Lawful Basis: Your explicit consent (GDPR Article 6.1.a), granted by actively filling out and checking the mandatory checkbox on our contact form.

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B. Commercial and Billing Management

• Data Collected: Identity data, fiscal details, billing address, and transaction data.
• Purpose: To manage the administrative, fiscal, and accounting relationship derived from providing our professional services.
• Lawful Basis: The execution of a contract or pre-contractual relationship (GDPR Article 6.1.b) and compliance with legal tax obligations under Spanish law (GDPR Article 6.1.c).

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3. DATA RECIPIENTS AND INTERNATIONAL TRANSFERS

We do not sell, rent, or share your personal data with third parties for marketing purposes. However, to keep our website operational, your data is shared with the following mandatory provider:

• Data Processor: Webflow, Inc. (398 11th Street, 2nd Floor, San Francisco, CA 94103, USA). Webflow hosts our website infrastructure and securely processes form submissions on our behalf.
• International Data Transfer: Because Webflow utilizes cloud infrastructure located in the United States, an international data transfer occurs when you submit a form.
• Legal Safeguards: This transfer is fully authorized and lawful under GDPR Article 46. Webflow, Inc. is certified under the EU-U.S. Data Privacy Framework and executes Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring your personal data is protected to a level equivalent to EU standards.

Apart from Webflow, data may be disclosed to public authorities, courts, or Spanish tax authorities (Agencia Tributaria) exclusively when required by Spanish or European law.

be kept only for as long as necessary to fulfill the purpose for which it was collected (e.g., to answer

4. DATA RETENTION AND MANDATORY "BLOCKING" OBLIGATION

Your personal data will be kept only for as long as necessary to fulfill the purpose for which it was collected (e.g., answering your contact inquiry).

Once the purpose ends, or if you request its deletion, we will not destroy the data immediately. In strict compliance with Artículo 32 of the Spanish LOPDGDD, your data will undergo a "Data Blocking" (Bloqueo de Datos) process.

• What this means: The data will be completely restricted and removed from active use. It will only remain accessible to judges, courts, the Public Prosecutor's Office, or competent Public Administrations (such as the AEPD) to handle potential legal liabilities arising from the processing.
• Retention period: The data will remain blocked for the duration of the statute of limitations for legal or tax actions under Spanish law (typically between 3 to 5 years), after which it will be permanently and securely destroyed.

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5. YOUR DATA PROTECTION RIGHTS

Under the GDPR and LOPDGDD, you hold comprehensive rights regarding your personal data. You may exercise the following rights at any time completely free of charge:

• Access: Find out if we are processing your data and get a copy of it.
• Rectification: Correct inaccurate, incomplete, or outdated information.
• Erasure (Right to be Forgotten): Request that your data be deleted (subject to the blocking obligations mentioned in Section 4).
• Restriction of Processing: Request that we temporarily pause the processing of your data under specific legal conditions.
• Data Portability: Receive your data in a structured, commonly used electronic format to transmit it to another controller.
• Objection: Object to the processing of your data based on legitimate business interest or for direct marketing.

How to exercise your rights:

To exercise any of these rights, you must send a written request to our contact email address: info@modulate.am.
You must state your full name and clearly specify the right you wish to exercise.

If you believe that your data protection rights have been violated by us, you have the right to lodge a formal complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos - AEPD) via their official website at www.aepd.es.